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Case 1:20-cr-00330-PAE Document 335 Filed 09/03/21 Page2of3 must balance the risk of surprise to the defendant, which is enhanced if ‘there are a large number of co-conspirators and a long-running conspiracy’ with legitimate law enforcement concerns, such as the potential danger to co-conspirators and the risk of compromising continuing investigations.’” United States v. Akhavan, No. S3 20-CR-188(JSR), 2020 WL 2555333, at *2 (S.D.N.Y. May 20, 2020) (quoting United States v. Pinto-Thomaz, 352 F. Supp. 3d 287, 303 (S.D.N.Y. 2018). The conspiracies charged are long-running, increasing the risk of surprise to the Defendant. See Akhavan, 2020 WL 2555333, at *2. Count Three charges Maxwell with a conspiracy running from 1994 to 2004 and Count Five charges a conspiracy running from 2001 to 2004. Dkt. No. 187 49 17, 23. And as the Court has previously found, Maxwell is likely able to determine the names of the alleged victims described in the Indictment due to the Government’s extensive discovery, see Dkt. No. 207 at 20; however, this logic does not necessarily extend to the identities of alleged co-conspirators. See Bin Laden, 92 F. Supp. 2d at 241. The Government argues that there is no risk of surprise because “it currently intends” to introduce the alleged co-conspirator statements of only two individuals. Dkt. No. 320 at 2. At the same time, however, the Government proffers that it “may change its view as it prepares for trial.” Dkt. No. 320 at 2. The Court thus finds the Government’s reassurance hollow and insufficient to ensure that the Defendant may adequately prepare her defenses. See Pinto- Thomas, 352 F. Supp. 3d at 301-02. Moreover, the Government has not alleged that disclosure here would create “potential danger to co-conspirators” or risk “compromising continuing investigations.” See Akhavan, 2020 WL 2555333, at *2. It merely argues that disclosing the identities risks “harm to the DOJ-OGR-00005041